Transcript Tuberculosis - the Mining Quiz List

Overview of CPL 2.106,
Enforcement Procedures and
Scheduling for Occupational
Exposure to Tuberculosis (TB)
TB Occurrence
• Since 1985, the incidence of TB in the
general population has increased 14%
reversing a 30 year downward trend
• In 1993, over 25,000 new cases of TB were
reported in the U.S.
• During 1994 and 1995, however, there was
a decrease in TB cases in the U.S. likely
due to increased awareness and efforts in
prevention and control of TB
TB Occurrence (Continued)
• Cases of multi-drug resistant (MDR)
TB have recently been reported in 40
states
• Worldwide, 8 million new TB cases
and 3 million deaths occur annually
Why Is TB Increasing?
Multiple contributing factors:
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Homelessness
Intravenous drug use
Overcrowding in institutional settings
HIV infection
Reduced TB control and treatment
resources
• Immigration from high TB prevalence areas
TB Transmission
• Infectious disease cause by the bacterium,
Mycobacterium tuberculosis
• Spread by airborne droplets, “droplet
nuclei,” 1 to 5 microns in size
• Droplet nuclei generated when a person
with TB disease coughs, sneezes, speaks,
or sing
• TB infection occurs when a susceptible
person inhales droplet nuclei containing the
bacteria becomes established in the body
General Signs and
Symptoms of TB
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Lethargy/weakness/fatigue
Fever
Weight loss
Persistent productive cough
Coughing up blood
Loss of appetite
Night sweats
TB Screening
• Mantoux tuberculin skin test detects
TB infection
• Positive result indicate TB infection;
• other tests are needed to confirm TB
disease
Summary of OSHA
TB Enforcement Activities
• 5/92: OSHA Region 2 issued enforcement
guidelines for occupational exposure to TB
• Guidelines based on CDC 1990 “Guidelines
for Preventing the Transmission of
Tuberculosis in Health Care Settings with
Special Focus on HIV-Related Issues”
• OSHA inspections revealed that employers
have not fully implemented the CDC
guidelines
Summary (Continued)
• 10/93: OSHA issued agency-wide TB
enforcement policy guidelines based on the
CDC 1990 guidelines. Guidelines were
effective immediately except for respirator
requirements which became effective 1/94
• 2/96: OSHA issued agency-wide CPL 2.106,
“Enforcement Procedures and Scheduling
for Occupational Exposure to Tuberculosis”
which cancels the enforcement policy
guidelines
Summary (Continued)
• CPL 2.106 is based on CDC 1994
“Guidelines for Preventing the Transmission
of Mycobacterium tuberculosis in HealthCare Facilities” issued 10/94
• OSHA believes the guidelines reflect an
industry recognition of the hazard as well as
appropriate widely accepted standards of
practice to be followed by employers in
carrying out their responsibilities the OSH
Act
Inspection
Scheduling and Scope
• The evaluation of occupational exposure
to TB is conducted in response to:
– Employee complaints;
– Related fatality/catastrophes; or
– As part of all industrial hygiene
inspections conducted in workplaces
identified by the CDC as having a greater
incidence of TB infection than in the
general population.
Inspection Scheduling and
Scope (Continued)
• CDC has identified the following
workplaces as having high incidences
of TB:
– Healthcare Facilities
– Correctional Institutions
– Homeless Shelters
– Long-term Care Facilities for the Elderly
– Drug Treatment Centers
Inspection Scheduling
and Scope (Continued)
• Health care facilities include hospitals where
patients with confirmed or suspect TB are
treated or to which they are transported
• Coverage of non-health care setting includes
only personnel present during performance of
high hazard procedures on suspect or active
TB patients
• Dental health care personnel are covered only
if they treat suspect or active patients in a
hospital, correctional facility, or as part of their
practice.
Inspection Scheduling
and Scope (Continued)
All inspections in affected workplaces shall include a
review of employer’s plans for employee TB
protection, if any. Such plans may include the
infection control program, respiratory protection, and
skin testing. Employee interviews and site
observations are an integral part of the process
evaluation
Complaints received from state and local
government employees outside federal jurisdiction
in federal enforcement states are referred to the
appropriate agency by the Area Office
Inspection Procedures
• Procedures in the FIRM, Chapter II, are
followed except as modified in the following:
– Upon entry, CSHO shall request the
presence of infection control director and
employee occupational health professional
responsible for occupational hazard control
– CSHO shall establish whether or not the
facility had a suspect or confirmed TB case
within last 6 months to determine coverage
under the OSH Act
Inspection Procedures (Continued)
• If the facility has had a suspect or
confirmed TB case within the previous 6
months, the CSHO shall proceed with the
TB portion of the inspection
• CSHO shall verify the implementation of
the employer’s plans for TB protection
through employee interviews and direct
observation where feasible
Inspection Procedures (Continued)
• After review of the facility plans for worker
protection, employee interviews combined
with an inspection of the facility shall be
used to determine compliance
• CSHO who perform smoke-trail visualization
tests should review protocol and be
prepared to present employer with MSD for
the smoke that is released on a smoke-trail
visualization
Compliance Officer Protection
• Area Directors or Assistant Area Directors
shall ensure that CSHOs performing TB
related inspections are familiar with the
CDC guidelines, terminology, and are
adequately trained in health care settings
• CSHO shall not enter occupied respiratory
isolation (acid fast bacilli) rooms unless, in
their determination, entry is required to
document a violation
Compliance Officer
Protection - Continued
• CSHOs shall exercise professional judgment
and extreme caution when engaging in
activities that may involve exposure to TB
• On rare occasions when entry into potentially
hazardous areas is judged necessary, CSHOs
shall wear negative pressure elastomeric face
piece respirators equipped with a HEPA filter
• CSHOs who conduct TB inspections shall have
been offered the TB skin test
Compliance Officer
Protection - Continued
• CSHOs exposed to an individual (s) with active
infectious TB shall receive a follow-up examination
• If an isolation room is occupied by a patient with
confirmed or suspect TB or has not been
adequately purged when a smoke-trail is
performed, then the CSHO should assume that the
isolation room is not under negative pressure
• Under such circumstances, CSHOs shall wear
negative pressure HEPA respirators when
performing test or entry into room is necessary
Citation Policy
• The following requirements apply when
citing hazards found in target workplaces.
Employers must comply with the provisions
of these requirements whenever an
employee may be occupationally exposed to
TB:
– Section 5 (a)(1) - General Duty Clause and
Executive Order 12196, Section 1-201(a) for
federal facilities
– 29 CFR 1910.134 - Respiratory Protection
Citation Policy (Continued)
• 29 CFR 1910.145 - Accident
Prevention Signs and Tags
• 29 CFR 1910.20 - Access to Employee
Exposure and Medical Records
• 29 CFR 1904 - Recording and
Reporting Occupational Injuries and
Illnesses
Violations
All elements listed in the citation policy
section must be addressed to ensure
adequate protection of employees from
TB hazards. Violations of these OSHA
requirements will normally be classified
as serious
General Duty Clause
Section 5 (a)(1) of the OSH Act states:
“Each employer shall furnish to each of
his employees employment and a place
of employment which are free from
recognized hazards that are causing or
are likely to cause death or serious
physical harm to his employees”
General Duty Clause (Continued)
• Section 5 (a)(1) citations must meet the
requirements outlined in the FIRM, and shall
be issued only when there is no standard
that applies to the particular hazard
• The hazard, not the absence of a particular
means of abatement, is the basis for a
general duty clause citation
• All applicable abatement methods identified
as correcting the same hazard shall be
issued under a single 5 (a)(1) citation
General Duty Clause (Continued)
Four required elements necessary for issuing
general duty clause violations include:
– The employer failed to keep the workplace free of a
hazard to which employees of that employer were
exposed
– The hazard was recognized
– The hazard was causing or was likely to cause death
or serious physical harm
– There was a feasible and useful method to correct
the hazard
General Duty Clause (Continued)
Citations shall be issued to employers with
employees working in one of the workplaces
where the CDC has identified workers as having
a higher incidence of TB infection than the
general population, when the employees are not
provided appropriate protection and who have
exposure as defined as:
Exposure to the exhaled air of an individual
with suspected or confirmed pulmonary TB
disease, or
General Duty Clause (Continued)
Employee exposure without appropriate
protection to a high hazard procedure
performed on an individual with suspected
or confirmed infectious TB disease and
which has the potential to generate
infectious airborne droplet nuclei
High Hazard Procedures
• Characterized by potential to generate
airborne secretions
• Aerosolized medication treatment
• Bronchoscopy
• Sputum induction
• Endotracheal intubation and suctioning
• Autopsies conducted in hospitals
Feasible and Useful
Abatement Methods
• Protocol for the early identification of
individuals with active tuberculosis
• Medical surveillance
• Case management of infected
employees
• Worker training and education
• Engineering controls
Feasible and Useful
Abatement Methods (Continued)
The protocol for the early identification of
individuals with active TB shall include the
following elements:
– Assignment of responsibility for the TB infection
control program;
– Conduct risk assessment;
– Develop TB infection control plan;
– Periodically reassess risk;
– Identification, evaluation, and treatment for
patients who may have active TB
Feasible and Useful
Abatement Methods (Continued)
• Management of patients who may
have TB in ambulatory-care settings
and emergency departments
• Management of hospitalized patients
who may have TB;
• Engineering controls;
• Respiratory protection
Feasible and Useful
Abatement Methods (Continued)
• Cough-inducing and aerosol-generating
procedures;
• Educating and training health care workers;
• Evaluating health care workers PPD test
conversions and possible nosocomial
transmission of M. tuberculosis; and
Coordination of efforts with the public health
department
Feasible and Useful
Abatement Methods (Continued)
• Medical surveillance includes:
– Initial examinations for new and
current employees exposed to TB
– Periodic TB skin test evaluations; and
– Reassessment of employees following
exposure or change in health
Feasible and Useful
Abatement Methods (Continued)
• Case management of infected
employees includes:
– Protocol for new converters
– Work restrictions for infectious
employees
Feasible and Useful
Abatement Methods (Continued)
• Training and education include such
issues as:
– The mode of TB transmission;
– TB signs and symptoms;
– Medical surveillance and therapy; and
– Site specific protocol
Feasible and Useful
Abatement Methods (Continued)
• Engineering controls include:
– Placement of individuals with suspected or
confirmed infectious TB in a respiratory acidfast bacilli (AFB) isolation room;
– Maintaining isolation and treatment rooms
under negative pressure;
– Exhausting air from AFB isolation or
treatment rooms outside instead of
recirculation into general ventilation system
Feasible and Useful
Abatement Methods (Continued)
• Engineering controls (continued):
– Maintaining under negative pressure
all potentially contaminated air which is
ducted through the facility until it is
discharges; and
– Decontamination of air from the
isolation and treatment rooms before
circulation back to the
isolation/treatment rooms
Respiratory Protection
• Respirators shall be provided by the
employer when such:
– equipment is necessary to protect the
health of the employee
– equipment is applicable and suitable for
the purpose intended
The establishment and maintenance of the
respiratory protective program shall be the
responsibility of the employer
Respiratory Protection (Continued)
• The 1994 CDC Guidelines specify the
following criteria for respirators for exposure
to TB:
– Ability to filter 1 micron in size in the
unloaded state with a filter efficiency
greater than 95%;
– ability to be qualitatively or quantitatively
fir tested in a reliable way to obtain faceseal leakage of less than 10%
Respiratory Protection (Continued)
• CDC Guidelines (continued):
– The ability to fit the different facial sizes and
characteristics of health care workers which
can usually be met by making the respirators
available in at least three sizes
– The ability to be checked for face piece fit in
accordance with OSHA standards and good
industrial hygiene practice, by health care
workers each time they put on their
respirator
Respiratory Protection (Continued)
• Under the new NIOSH criteria, filter
materials would be tested at a flow rate of
85 lpm for penetration by particles with a
medial aerodynamic diameter of 0.3 um and
if certified would be placed in one of the
following categories:
– Type 100 (99.7% efficient)
– Type 99 (99% efficient)
– Type 95 (95% efficient)
Respiratory Protection (Continued)
The minimal acceptable level of respirator
protection for TB is the Type 95 respirator.
Classes of these air purifying, particulate
respirators to be certified are described
under 42 CFR Part 84 Subpart K
Until these classes of respirators are
commercially available, the minimal
acceptable respiratory protection that meets
the criteria will remain the HEPA filter
Respiratory Protection (Continued)
• Employees must wear HEPA or respirators
certified under 42 CFR Part 84 Subpart K in the
following circumstances:
– When workers enter rooms housing individuals
suspected or confirmed TB disease
– When workers perform high hazard procedures
on persons who have suspected or confirmed
TB disease
– When emergency response employees or
others must transport in a closed vehicle, an
individual with suspected or confirmed TB
disease
Respiratory Protection (Continued)
When respiratory protection is required, a
complete respiratory protection program
must be in place in accordance with 29 CFR
1910.14 (b) and include the following
elements:
– Written operating procedures
– Proper selection
– Training and fitting
– Cleaning and disinfecting
Respiratory Protection (Continued)
• Respirator program elements
(continued):
– Storage
– Inspection and maintenance
– Work surveillance
– Inspection/evaluation of program
– Approved respirators
Access to Employee
Medical and Exposure Records
• A record concerning employee exposure to TB
is an employee exposure within the meaning of
29 CFR 1910.20
• A record of TB skin test results and medical
evaluations and treatments are employee
medical records within the meaning of 29 CFR
1910.20
• These records shall be handled according to 29
CFR 1913.10 in order for the CSHO to
determine compliance with 29 CFR 1910.20
Accident Prevention
Signs and Tags
In accordance with 1910.145 (f)(8), a warning
shall be posted outside the respiratory isolation
or treatment room or a message referring one to
the nursing station for instruction may be posted.
1910.145 (f)(4) requires that a signal word or
biological hazard symbol may be presented as
well as a major message
Accident Prevention
Signs and Tags (Continued)
Employers are also required to use
biological hazard tags on air transport
components which identify TB hazards to
employees associated with working on air
systems that transport contaminated air
OSHA 200 Log
• For OSHA 200 recordkeeping purposes, both TB
infections (positive TB skin tests) and TB disease
are recordable in the high risk settings
• If the employee’s TB infection which was entered
on the OSHA 200 log progresses to TB disease
during the 5 year maintenance period, the original
entry for the infection must be updated to reflect
new information
• A positive TB skin test provided within two weeks of
employment does not have to be recorded on the
OSHA 200 form